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41. PLR 201643014 — Qualified Governmental Excess Benefit Plans
    IRCPrivate Letter RulingsOct 21, 2016
    … applies to nonqualified plans of deferred compensation, including excess benefit plans, in various revenue rulings. In Rev. Rul. 60-31, Situations 1 – 3, the Service held that a mere promise to pay, not represented by notes or secured in any way, does not constitute receipt of income by a cash basis taxpayer. Rev. Rul…
42. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980related by meaning
    …-406, 88 Stat. 829, sec. 203. On Sept. 10, 1974, shortly after the enactment of ERISA, the Internal Revenue Service issued T.I.R. 1308 published as Rev. Proc. 74-38, 1974-2 C.B. 492, which covered the procedure for plans for the year 1974 adopted after Sept. 2, 1974. Rev. Proc. 74-38 provides in part, 1974-2 C.B. at 49…
43. Rev. Rul. 2006-43 — Government pick-up plans; employer contributions; income tax; prospective application. This ruling describes the actions required for a state or its political …
    IRCRevenue RulingsAug 28, 2006
    …contributions to meet the requirements set forth above in paragraph (1) of Law and Analysis in this revenue ruling. The relief provided above for “pick-ups” implemented prior to August 28, 2006, applies only if the actions taken otherwise complied with Rev. Rul. 81-35, Rev. Rul. 81-36, and Rev. Rul. 87-10, and only if …
44. Rev. Proc. 2014-8 — User fees for employee plans and exempt organizations. Current guidance for complying with the user fee program of the Service as it pertains to requests for l…
    IRCRevenue ProceduresJan 2, 2014
    istrative scrutiny determination Rev. Proc. 93–41 Adoption agreement Rev. Procs. 2011–49, 2013–22 Advisory letter Rev. Procs. 2011–49, 2013–22, 2014–6 Basic plan document Rev. Procs. 2011–49, 2013–22 Determination letter Rev. Procs. 2014–6, 2014–9 Dual-purpose IRA Rev. Procs. 98–59, 2010–48 Group exemption letter Rev. …
45. Rev. Rul. 2014-24 — This revenue ruling modifies the list of group trust retiree benefit plans eligible to participate in 81–100 group trusts in accordance with the requirements o…
    IRCRevenue RulingsSep 8, 2014
    …splaced by the disaster and modifies other requirements of § 142(d) to accommodate this suspension. Rev. Proc. 2014–51 Rev. Proc. 2014–51 This revenue procedure provides guidance on certain aspects of an entity’s qualification as a real estate investment trust (REIT) in the context of transactions involving debt secure…
46. Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k…
    IRCNoticesJun 8, 2026
    term rate is set forth for the month of June 2026. See Rev. Rul. 2026-11, page 1570. Section 467.—Certain Payments for the Use of Property or Services The applicable federal short-term, mid-term, and long-term rates are set forth for the month of June 2026. See Rev. Rul. 2026-11, page 1570. Section 468.—Special Rules f…
47. PLR 201519001 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsMay 8, 2015
    . Rev. Rul. 77-85, 1977-1 C.B. 12, Rev. Rul. 80-274, 1980-2 C.B. 27, Rev. Rul. 81-225, Rev. Rul. 82-54, 1982-1 C.B. 11, Rev. Rul. 2003-91, 2003-2 C.B. 347, and Rev. Rul. 2003-92, 2003-2 C.B. 350. The rulings stand for the proposition that contract holders possessing control over the investment of the separate account a…
48. PLR 199934002 — Deferred Compensation
    IRCPrivate Letter RulingsAug 27, 1999
    …al or is not relevant to the issue presented in this technical advice request. 5 The application of Rev. Rul. 54-608 was delayed by Rev. Rul. 55-246, 1955-1 C.B. 68; Rev. Rul. 56-315, 1956-2 C.B. 304; Rev. Rul. 57-28, 1957-1 C.B. 193; and Rev. Rul. 57-325, 1957-2 C.B. 302. Congress further delayed the application of Re…
49. PLR 200641008 — Governmental Plan
    IRCPrivate Letter RulingsOct 13, 2006
    …ge for such insurance is unreasonably large in relation to the total charges under the contract. In Rev. Rul. 75-302 , 1975-2 C.B. 86, Rev. Rul. 75-303, 1975-2 C.B. 87, and Rev. Rul. 76 - 481, 1976-2 C.B. 82, taxpayers were allowed a current deduction of payments for future medical care extendi ng substantially beyond …
50. 66 T.C. 82 — Sarmir v. Commissioner
    IRCCourt RulingsApr 12, 1976
    …f simplicity the partial termination of the plan is referred to as the termination of the plan. See Rev. Rul. 58-94, 1958-1 C.B. 194; Rev. Rul. 58-95, 1958-1 C.B. 197; Rev. Rul. 58-96,1958-1 C.B. 200; Rev. Rul. 58-97,1958-1 C.B. 201; Rev. Rul. 58-98,1958-1 C.B. 202; Rev. Rul. 58-383,1958-2 C.B. 149; Rev. Rul. 65-147,19…
51. Notice 2014-19 — The purpose of this notice is to provide guidance on the application (including the retroactive application) of the decision in United States v. Windsor, 570 U…
    IRCNoticesApr 21, 2014
    …, must a qualified retirement plan be amended to reflect the outcome of Windsor and the guidance in Rev. Rul. 2013–17 and this notice? A–4. Whether a plan must be amended to reflect the outcome of Windsor and the guidance in Rev. Rul. 2013–17 and this notice depends on the terms of the specific plan, as described in Q&…
52. Rev. Proc. 2017-57 — This revenue procedure updates Rev. Proc. 2000–41 to take into account the enactment of subsequent legislation. This revenue procedure sets forth the procedure…
    IRCRevenue ProceduresOct 30, 2017related by meaning
    …the use of the class ruling, or decline to issue a class ruling. SECTION 6. REQUESTING APPROVAL FOR REVOCATION OF AN INTEREST RATE ELECTION
53. Rev. Rul. 2008-13 — Performance-based compensation. This ruling holds that compensation paid to an executive is not qualified performance-based compensation for purposes of sectio…
    IRCRevenue RulingsMar 10, 2008
    INCOME TAX Rev. Rul. 2008-11 Rev. Rul. 2008-11 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for March 2008. Rev. Rul. 2008-12 Rev. Rul. 2008-12 Application o…
54. Rev. Proc. 2005-76 — Retroactive payment of benefits; multiemployer plan; discretionary relief; extension. This procedure extends the date by which certain qualified retirement pla…
    IRCRevenue ProceduresDec 12, 2005related by meaning
    Rev. Proc. 2005-76 SECTION 1. PURPOSE The purpose of this revenue procedure is to extend the date by which a qualified retirement plan must be in operational compliance with a reforming plan amendment in order to be eligible for the treatment described in section 3.02 of Revenue Procedure 2005-23, 2005-18 I.R.B. 991, r…
55. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984
    …(Supp.) 80, 129. Both parties have devoted considerable attention on brief to a discussion of three revenue rulings: Rev. Rul. 72-439, 1972-2 C.B. 223 (partial termination occurred when a union contract caused 120 of the plan’s 170 participants to become ineligible to participate in the plan); Rev. Rul. 73-284, 1973-2 …
56. PLR 201240018 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsOct 5, 2012
    …counting Principles, a synthetic lease is viewed as a secured loan by the IRS for tax purposes." 20 Rev. Rul. 77-85, 1977-1 C.B. 12; Rev. Rul. 80-274, 1980-2 C.B. 27; Rev. Rul. 81-225, 1981-2 C.B. 12; and Rev. Rul. 82-55, 1982-1 C.B. 12. See also Rev. Proc. 99-44, 1999-2 C.B. 598. 21 Rev. Rul. 2003-91, 2003-2 C.B. 347,…
57. T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o…
    IRCTreasury DecisionsMay 29, 2007
    INCOME TAX Rev. Rul. 2007-34 Rev. Rul. 2007-34 LIFO; price indexes; department stores. The March 2007 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referen…
58. Notice 2005-101 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66 pertaining to the statutory, regul…
    IRCNoticesDec 27, 2005
    …)(v) of the Code and the applicable mortality table under § 417(e)(3)(A)(ii)(I) of the Code. (New). Rev. Rul. 2002-42, 2002-1 C.B. 76, provides guidance with respect to a situation where a money purchase pension plan is merged or converted into a profit sharing plan. Rev. Proc. 2002-21, 2002-1 C.B. 911, provides guidan…
59. PLR 201515001 — Included vs. Not Included in Gross Income
    IRCPrivate Letter RulingsApr 10, 2015
    … Service applied these general tax ownership principles in a series of “investor con trol” rulings. Rev. Rul. 77-85, 1977-1 C.B. 12, Rev. Rul. 80-274, 1980-2 C.B. 27, Rev. Rul. 81-225, Rev. Rul. 82-54, 1982-1 C.B. 11, Rev. Rul. 2003-91, 2003-2 C.B. 347, and Rev. Rul. 2003-92, 2003-2 C.B. 350. The rulings stand for the …
60. PLR 199905003 — Nonqualified Annuities
    IRCPrivate Letter RulingsFeb 5, 1999
    ions. Various revenue rulings have considered the tax consequences of nonqualified deferred compensation arrangements. Rev. Rul. 60-31, Situations 1-3 , 1960-1 C.B. 174, holds that a mere promise to pay, not represented by notes or secured in any way, does not constitute receipt of income within the meaning of the cash…